tag:blogger.com,1999:blog-12154253.post5647982694124508911..comments2024-03-20T00:33:13.961-05:00Comments on Customs Law: Customs Business vs. ComplianceLarryhttp://www.blogger.com/profile/13659537105506728479noreply@blogger.comBlogger4125tag:blogger.com,1999:blog-12154253.post-22665699882121528992012-08-02T18:41:51.758-05:002012-08-02T18:41:51.758-05:00I was one of the victims to take the recent Custom...I was one of the victims to take the recent Customs Broker Exam which had a pass rate of 1% Unfortunately I was not one of the 1% but I definitely agree that Customs needs to re-evaluate the test. There is just too much material and not enough time to look up the answers. Wish me luck as I take the next exam in October!Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-12154253.post-11611617117789142612012-08-01T13:56:39.278-05:002012-08-01T13:56:39.278-05:00: I think also of note is a recent tendency on the...: I think also of note is a recent tendency on the part of businesses to cut corners, particularly finding loopholes in duty charges as of late.Sarahhttp://onlinedegree.botw.org/lawnoreply@blogger.comtag:blogger.com,1999:blog-12154253.post-90099640958731706902012-07-31T16:48:03.885-05:002012-07-31T16:48:03.885-05:00What you are asking for is dangerously close to pr...What you are asking for is dangerously close to practicing law, which I don't do here on the blog. I can tell you this. Yes, companies have made arrangements under which the compliance person is an employee of multiple business entities. Some companies have also created entities solely for the purpose of acting as licensed brokers. Either will work. One new worry, based on the ruling cited in the post, is whether you can work for two or more entities during overlapping time. Regardless, this is a hassle and needs to be fixed. Personally, I would interpret the law and pass a regulation extending the definitions of employer and importer to cover related companies, provided that both the parent company and the non-employer companies authorize the representation by the compliance person. That might not work, but it is a starting point.Larryhttps://www.blogger.com/profile/13659537105506728479noreply@blogger.comtag:blogger.com,1999:blog-12154253.post-81607952831989598332012-07-30T17:06:22.812-05:002012-07-30T17:06:22.812-05:00As a Licensed Customs Broker and in-house Internat...As a Licensed Customs Broker and in-house International Compliance Manager, so understand needing a clearer definition of "Customs Business". There are a lot of gray areas working with subsidiaries and other related partners, and generally agree with your analysis. <br /><br />After speaking with counsel on the topic, it was suggested that either the company creates its own customs brokerage entity (which I know occurs at other businesses as well), or that I am a paid employee by all the companies (something else I have done in other companies). Do you find these are the most common way for a licensed broker to get around these issues? I so happen to be in law school, and would think this would also alleviate some of these requirements as an attorney. I would love you opinion on the matter as well. Thank you.Anonymousnoreply@blogger.com